Improving Voluntary Compliance: Reform the IRS Criminal Voluntary Disclosure Practice

…Identifying Barriers to Participation in the VDP While the VDP is intended to offer taxpayers a structured pathway to compliance, changes implemented in 2018 and 2024 have inadvertently created significant…

Analysis of the Revised Form 14457: Key Changes to the IRS Voluntary Disclosure Practice

…stricter deadlines, and full payment of liabilities, the IRS deters taxpayers with genuine intent to resolve past issues via the VDP. Taxpayers must approach the VDP with careful planning, robust…

IRS Quietly Changes its Voluntary Disclosure Practice For the Worse

The IRS’s Voluntary Disclosure Practice (VDP) allows noncompliant taxpayers who have failed to meet their tax obligations to come into compliance and avoid criminal prosecution. Financially, the VDP offers the…

The New IRS ERC Voluntary Disclosure Program

…potential civil litigation, penalties & interest. Under the ERC VDP, if the IRS paid interest on the employer’s ERC refund claim, the employer is not required to repay that interest….

IRS announces an update to its Voluntary Disclosure Practice Preclearance Request and Application

…need to disclose virtual currency transaction federal income tax consequences should avail themselves of this expanded opportunity to report their virtual currencies via the IRS CI VDP and avoid potential…

How to Avoid Criminal Prosecution Through Voluntary Disclosure

…not qualify for VDP. Another aspect of voluntary disclosure is that it must be timely as well. To be timely according to the IRS, they have to receive the disclosure…

All the Many FBAR Late Filing Procedures

…Taxpayers with undisclosed foreign income and assets. In 2018 the IRS closed this program and expanded the VDP Program. The new VDP Program is primarily for taxpayers who are considered…

New Comments on the IRS Voluntary Disclosure Program

…or start-up costs and costs of operation, maintenance, and purchase of services to provide information. Form 14457 relates to the Service’s Voluntary Disclosure Practice (“VDP”). The VDP is a longstanding…

How to Avoid Jail and Clean Up Tax Problems

…as the Voluntary Disclosure Practice (VDP). A taxpayer seeking to make a voluntary disclosure must do so by first requesting preclearance on Form 14457, Voluntary Disclosure Practice Preclearance Request and…

The New IRS Voluntary Disclosure Practice: Not a Good Deal for Noncompliant Taxpayers

…of cooperation. The VDP was announced via an IRS memorandum, not through the IRS website. The new VDP does not offer the finality and certainty that many noncompliant taxpayers wish…

IRS Updated Voluntary Disclosure Practice is a Game-Changer

Last week the IRS released a memorandum with new procedures for an “Updated Voluntary Disclosure Practice” impacting all voluntary disclosures. The new updated voluntary disclosure practice (VDP) is a game-changer…

Another Bank Discloses Accountholders: Credit Suisse to Turn Over U.S. Account Data

…to file a traditional voluntary disclosure via the IRS VDP program that would allow them to avoid potential criminal prosecution. In February 2009, UBS AG, the biggest Swiss bank, avoided…